Shipping and Air Transport
(1) Profits of an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
(2) If the place of effective management of a shipping enterprise is aboard a ship, then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship is situated, or, if there is no such home harbour, in the Contracting State of which the operator of the ship is a resident.
(3) The purposes of this Article profits from the operation of ships or aircraft in international traffic include:
- (a) profits from the rental on a bareboat basis of ships or aircraft;
- (b) profits from the use, maintenance or rental of containers, including trailers and related equipment for the transport of containers, used for the transport of goods or merchandise.
(4) The provisions of paragraph 1 shall also apply to profits derived from:
- (a) the participation in a pool, a joint business or an international operating agency;
- (b) selling of tickets on behalf of another enterprise;
- (c) income deriving from deposits at a bank, bonds, shares and stocks and other debentures provided that such investments are incidental with the operations of that shipping or air transport enterprise.